Global Minimum Tax Administration Act, 2024 (Act No. 47 of 2024)

2. Obligation to submit GloBE Information Return

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(1) A Domestic Constituent Entity of an MNE Group, Domestic Joint Venture or Domestic Joint Venture Subsidiary of a Domestic Joint Venture Group must apply for registration and submit a GloBE Information Return to the Commissioner.

[Section 2(1) substituted by section 25(a) of the Tax Administration Laws Amendment Act, 2026, Notice No. 7343, GG54447, dated 1 April 2026]

 

(2) A Designated Local Entity may submit the GloBE Information Return to the Commissioner on behalf of all Domestic Constituent Entities.

 

(3) Where subsection (2) applies—
(a) a Domestic Constituent Entity must provide to the Designated Local Entity all information necessary for the correct application of the Top-up Tax imposed under the Global Minimum Tax Act; and
(b) a Domestic Constituent Entity must—
(i) notify the Commissioner no later than six months prior to the filing due date of GloBE Information Return under section 3 of the identity of the Entity that is submitting the GloBE Information Return; and
(ii) if subsequent to a notice under subparagraph (i) a new Entity is designated as the Designated Local Entity, a new notification must be provided to the Commissioner upon or immediately after such new designation.

[Section 3(b)(ii) substituted by section 25(b) of the Tax Administration Laws Amendment Act, 2026, Notice No. 7343, GG54447, dated 1 April 2026]

 

(4) All Domestic Constituent Entities must submit the GloBE Information Return if—
(a) no designation is made in accordance with subsection (2);
(b) the Designated Local Entity is no longer a member of the same MNE Group as the Domestic Constituent Entities and the MNE Group does not appoint an alternative Designated Local Entity; or
(c) the Designated Local Entity fails to submit the return.